US FDA/CFSAN - Raw Milk-Associated Public Health Risks - Slide 12

Speaker's Notes

National Association of State Departments of Agriculture
Legislative & Regulatory/Policy Statements/FOOD REGULATION AND SAFETY
(September 18, 2006)
4.6 State Food Inspection Programs
Dairy Product Safety - As the distribution of dairy products moves from a regional to a national market, it is important that milk regulatory agencies utilize uniform interpretations of the FDA's Pasteurized Milk Ordinance (PMO) and USDA's Milk for Manufacturing Purposes and its Productions and Processing Recommended Requirements.
Passage of the GATT and NAFTA agreements are advancing the National Conference on Interstate Milk Shipments (NCIMS) into the area of international trade. State and federal milk regulators and the NCIMS Program must ensure that regulations are uniform and equivalent, providing a safe and wholesome product, while allowing international commerce to progress. Milk regulatory agencies and the NCIMS Program should have the following goals:

To produce a safe raw milk supply and provide safe finished products for the consumer.
To more efficiently use resources to continue to protect the public health, enhance food safety and accommodate a changing regulatory and industry environment without reducing milk safety.
Development of a system to allow the free flow of dairy products both domestically and internationally utilizing equivalent safety standards.
To enhance the oversight program through state field audits, program evaluations and when necessary, check ratings. To increase uniformity and ensure product safety.
To adopt the most recent edition of the Grade 'A' Pasteurized Milk Ordinance (PMO) and related documents.

Milk Quality: Pasteurization--Inasmuch as apparently healthy cows and goats can shed in their milk organisms which are pathogenic to human beings and may cause diseases such as brucellosis, Campylobacter enteritis, salmonellosis, and tuberculosis; and inasmuch as milk handlers may introduce pathogenic agents during the handling of unpasteurized milk (including certified raw milk), only pasteurized milk, milk products and properly aged cheeses should be sold for human consumption. Sale includes distribution by use of animal or herd sharing, bartering, exchange or agistment. In those states where the sale of unpasteurized milk is authorized, those products should be labeled, "Not Pasteurized and May Contain Organisms that cause Human Disease."
As a precondition for the importation of all dairy products (Grade A and Non-Grade A) into this country, the FDA should be required, through legislation or other means, to make a timely determination as to whether a dairy product proposed to be imported meets the sanitary standards of this country. The determination could be made by either (1) inspection of individual plants and farms by FDA or by FDA certified private firms or individuals; or (2) by FDA's determination that the foreign country's dairy inspection system is equivalent to that of the United States.